This Privacy Policy governs how PropXP Ltd collects, uses, stores, shares, and protects personal data in connection with your access to and use of the Services available at https://propxp.com (the “Service”) provided by PropXP Ltd, a limited liability company incorporated under Companies Act, Cap. 13.01 of the Revised Laws of Saint Lucia, with registration number 2025-00696, and its registered office at Ground Floor, Rodney Court Building, Rodney Bay, Gros Islet, Saint Lucia (“PropXP”, “us”, “we”, or “our”). PropXP is committed to safeguarding personal data in accordance with the Data Protection Act of Saint Lucia (the “DPA”) as amended and in force from time to time. PropXP is considered as “data controller” under the DPA meaning we determine the purposes and manner in which personal data is processed.

Your access to our Services is subject to your acceptance, without modification, of all of the terms and conditions contained herein and all other operating rules and policies published and that may be published from time to time by us.

Please read the Agreement carefully before accessing or using our Services. By accessing or using any part of our Services, you agree to be bound by these Terms. If you do not agree with any part of this Agreement, you may not access or use our Services.

PropXP Ltd does not provide virtual asset services, custody of digital assets, payment services, or money transmission services, and does not act as a financial institution, broker, or payment intermediary.

1. INTELLECTUAL PROPERTY

The Agreement does not transfer from us to you any of ours or third-party intellectual property, and all right, title, and interest in and to such property will remain (as between the parties) solely with PropXP and its licensors. You are granted a limited, non-exclusive, revocable permission to access and use the Services solely for their intended purpose, and you may not copy, distribute, modify, or otherwise use any of PropXP’s intellectual property without prior written authorization. Any unauthorized use is prohibited under the laws of Saint Lucia.

2. THIRD PARTY SERVICES

When using the Services, you may access third-party services, products, software, embeds, or applications developed by a third party (“Third Party Services”).

• Any use of a Third-Party Service is at your own risk. We are not responsible or liable for Third-Party websites or services.
• You acknowledge and agree that we are not responsible or liable for any damage or loss caused or alleged to be caused by or in connection with the use of any such content, goods or services available on or through any such websites or services.
• Where the use of Third-Party Services involves the processing of personal data, such processing will occur only under appropriate contractual or technical safeguards, as required by the applicable provisions of the DPA.
• We do not control how Third-Party Services handle personal data, and users are encouraged to review their privacy terms before engaging with them.

3. ACCOUNTS

Where use of any part of our Services requires an account, you agree to provide us with complete and accurate information when registering. You also acknowledge that providing accurate information is necessary for the lawful and fair processing of personal data under applicable law.

You are solely responsible and liable for all activity that occurs under your account and for keeping your account information up-to-date and your password secure. You must not share or misuse your access credentials

You must notify us immediately if you become aware of any unauthorized use of your account or any other breach of security. We may take reasonable steps, including security verification measures, to protect your account and the integrity of our systems in accordance with the DPA.

4. TERMINATION

We may suspend or restrict access to the Services in accordance with our Terms and Conditions and applicable agreements. Such actions do not affect our obligations regarding the lawful processing and protection of personal data under this Privacy Policy.

All provisions of this Privacy Policy and the Trader Agreement which by their nature should survive termination shall survive, including without limitation ownership provisions, warranty disclaimers, indemnity, and limitations of liability.

5. DISCLAIMER

Our Services are provided “AS IS” and “AS AVAILABLE” basis. PropXP and its suppliers and licensors disclaim all warranties of any kind, express or implied, including, without limitation, the warranties of merchantability, fitness for a particular purpose and non-infringement. Neither PropXP, nor its suppliers and licensors, makes any warranty that our Services will be error-free or uninterrupted. Nothing in this Disclaimer affects any obligations we may have as a data controller under the applicable provisions of the DPA, including our responsibilities relating to the lawful and secure processing of personal data.

6. PRIVACY & DATA PROTECTION NOTICE

We are committed to protecting your personal information. This section explains how we collect, use, store, and protect personal data in accordance with the applicable provisions of the DPA that are currently in force.

6.1 Data Controller and Lawful Basis: PropXP is the data controller responsible for determining the purposes and means of processing personal data collected through our Services, in accordance with the applicable provisions of the DPA. We process personal data only for lawful and specified purposes, including the performance of a contract with you, compliance with our legal or regulatory obligations, prevention of fraud or misuse, and our legitimate business interests in operating and improving the Services. Where consent is required for specific processing activities, we will obtain it prior to processing.

6.2 Information We Collect:

• Registration details: full name, email address, country of residence.
• Identity verification (KYC): proof of identity and proof of residence (before simulated funded accounts are issued or before eligibility for any performance-based reward).
• Usage data: login details, IP address, device/browser type.
• Payment details: limited billing information required for challenge fee processing, handled securely by trusted third-party providers. We do not store full payment card information.
• Any additional information you voluntarily provide when communicating with us

We collect only information that is adequate, relevant, and not excessive for the purposes for which it is processed, as required by applicable law.

Usage data may include cookies or similar tracking technologies used to ensure platform functionality and security. Where required by law, consent mechanisms are applied.

6.3 How We Use Information

We use your personal data to:

• Verify your identity and eligibility to access funded accounts.
• Operate and maintain the platform.
• Prevent fraud, abuse, or prohibited activity.
• Communicate with you about your account, challenges, and payouts.
• Comply with legal and record-keeping obligations.
• Ensure the fair and lawful processing of personal data in accordance with the DPA.

6.4 Data Retention: We retain personal data and verification documents for a minimum of seven (7) years from the date of last activity, or longer if required by law. Personal data will not be kept longer than necessary for the purposes for which it was collected.

6.5 Data Sharing: We do not sell personal data. Information may only be shared with:

• Trusted third-party service providers (e.g., payment processors, IT support) strictly for the operation of our Services.
• Regulatory or law enforcement authorities, if required by law.
• Such third parties are required to maintain appropriate confidentiality and data-protection safeguards.

6.6 International Transfers: As our services are accessible globally, your personal data may be transferred and processed outside of your home jurisdiction. Where this occurs, we implement reasonable safeguards in line with the applicable provisions of the DPA, including ensuring that the receiving jurisdiction or entity provides adequate protection or appropriate safeguards.

6.7 Data Security: We use technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction. While no system is fully secure, we strive to protect your data using industry best practices. These measures are implemented to meet the security obligations imposed on data controllers under the DPA.

6.8 Your Rights: Subject to applicable law, you may have the right to:

• Request confirmation of whether personal data relating to you is being processed;
• Request access to personal data held about you;
• Request correction or rectification of inaccurate or incomplete data;
• Request deletion of personal data where retention is no longer required by law;
• Object to or restrict certain processing activities;
• Withdraw consent where processing is based on consent (without affecting prior lawful processing).

7. JURISDICTION AND APPLICABLE LAW

Except to the extent any applicable law provides otherwise, the Agreement and any access to or use of our Services will be governed by the laws of Saint Lucia.

The proper venue for any disputes arising out of or relating to the Agreement and any access to or use of our Services will be the courts of Saint Lucia. Nothing in this clause limits our obligations, or your protections, under any mandatory provisions of the DPA.

8. CHANGES

PropXP reserves the right, at our sole discretion, to modify or replace these Terms at any time. If changes are material, we will notify you via our website, email or other communication before the changes take effect. The notice will designate a reasonable period of time after which the new terms will take effect. Continued use of our Services after such changes will constitute acceptance of the revised terms.

Where changes relate to the collection or processing of personal data, we will provide notice consistent with the principles of fairness and transparency required under the applicable provisions of the DPA.

9. POLICY REVIEW

This policy is reviewed at least annually, or more frequently in response to regulatory changes or operational shifts. The Company reserves the right to change this policy without further notice to you, provided that the changes do not significantly reduce yourrights under this policy. If the Company makes material changes, we will notify you by email or by means of a notice on the Company’s home page or by changing the version of the document including the date of the update which will be visible to the first page of this document. The latest and prevailing version of this Notice will at all times be available on the Company’s Website.

10. POLICY APPROVAL

This Policy was reviewed and approved by the Board of Directors of PropXP Ltd on 10.12.2025.

11. CONTACT

If you have any questions, requests, or concerns regarding this Privacy Policy, the way your personal data is handled, or your rights under applicable data protection laws, you may contact us at support@propxp.com

We encourage you to reach out if you would like to:

• Request access to, correction of, or deletion of your personal data;
• Exercise any other rights you may have under applicable data protection laws;
• Raise a concern about how your personal data is processed;
• Ask questions about our services or this Privacy Policy.

We will review and respond to all inquiries in a timely manner and in accordance with our legal obligations.